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WASTE DISCHARGE REQUIREMENTS ORDER R5-2015-0058-01 -20- SAN JOAQUIN COUNTY DEPARTMENT OF PUBLIC WORKS FOOTHILL SANITARY LANDFILL, INC. FOOTHILL LANDFILL SAN JOAQUIN COUNTY 83. No leachate is collected from unlined unit LF-1 because it does not have an LCRS. Leachate collected from compositely-lined Module 1 (including any leakage collected in the secondary sump) is generally returned to Module 1 via a return line to infusion points on the landfill top deck. Depending on needs and other factors, leachate may alternatively be routed to the onsite storage tank (located near the LFG flare station) for later application to M-1 (i.e., infusion and/or dust control) and Calaveras SI unit. 84. The Discharger proposes to continue the practice of returning leachate to the same module from which it was collected, or if necessary depending on operational factors, to another compositely-lined LF-2 module. No leachate may be discharged to Module I, however, since it is unlined and does not have an LCRS. Consistent with Title 27 and Subtitle D regulations, these WDRs allow the Discharger to continue returning landfill leachate to existing and future compositely-lined LF-2 modules, as proposed and if there is no comingling of LFG condensate from LF-1. These WDRs prohibit the discharge of leachate to LF-1, which is a separate, unlined MSW landfill unit, See Discharge Prohibition A.3 and Discharge Specification B.5. 85. Previous WDRs authorized the discharge of LFG condensate derived from unlined Module I to lined Module 1 because the two modules were considered to be within the same MSW landfill unit. The Discharger therefore historically commingled landfill gas collected from unlined Module I and lined Module 1 and discharged the condensate obtained from the commingled gas to Module 1’s LCRS sump. Given that these WDRs classify Module I as a separate, existing MSW landfill unit (LF-1), the Discharger is no longer authorized to discharge condensate derived from unlined LF-1 (Module I) to existing or future LF-2 modules. These WDRs require that the Discharger submit an operations plan for the LFG extraction system, including a plan to handle LFG condensate derived from LF-1 separately so that it can be appropriately discharged to an authorized Class II surface impoundment. See Discharge Prohibition A.3.b, Discharge Specification B.9, and Facility Specification C.1 and C.3. LANDFILL DESIGN AND CONSTRUCTION 86. On 17 June 1993, the State Water Board adopted Resolution 93-62 implementing a State Policy for the construction, monitoring, and operation of municipal solid waste landfills that is consistent with the federal municipal solid waste regulations promulgated under 40 Code of Federal Regulations section 258 (Subtitle D). Resolution 93-62 requires the construction of a specified composite liner system at new municipal solid waste landfills, or expansion areas of existing municipal solid waste landfills, that receive wastes after 9 October 1993. Resolution 93-62 also allows the Central Valley Water Board to consider the approval of engineered alternatives to the prescriptive standard. Section III.A.b. of Resolution 93-62 requires that the engineered alternative liner systems be of a composite design similar to the prescriptive standard. 87. Title 27, section 20080(b) allows the Central Valley Water Board to consider the approval of an engineered alternative design (EAD) to the prescriptive standard. In order to approve an EAD in accordance with Title 27, sections 20080(c)(1) and (2), the Discharger must demonstrate that the prescriptive design is unreasonably and unnecessarily burdensome and will cost substantially more than an alternative which